DoD Announces Higher Certified Cost or Pricing Data Threshold

The Department of Defense has issued Class Deviation 2018-O0012, which raises the threshold for obtaining certified cost or pricing data to $2 million.

FAR 15.403-4 sets the threshold for obtaining CCPD at $750,000. However, section 811 of the National Defense Authorization Act for Fiscal Year 2018 (PL 115-91) increased the threshold for obtaining CCPD under the Truth in Negotiations Act (10 USC 2306a) and 41 USC 3502 from $750,000 to $2 million.

Since 41 USC 1502(B)(1)(B) equates the cost accounting standards threshold to the TINA threshold for obtaining CCPD, DoD has also increased the threshold for CAS applicability to $2 million.

The class deviation includes five deviated clauses/provisions and directs contracting officers to use them in lieu of FAR 52.230-1 through FAR 52.230-5:

  • 230-1 Cost Accounting Standards Notices and Certification (DEVIATION 2018-O0012)
  • 230-2 Cost Accounting Standards (DEVIATION 2018-O0012)
  • 230-3 Disclosure and Consistency of Cost Accounting Practices (DEVIATION 2018-O0012)
  • 230-4 Disclosure and Consistency of Cost Accounting Practices—Foreign Concerns (DEVIATION 2018-O0012)
  • 230-5 Cost Accounting Standards—Educational Institution (DEVIATION 2018-O0012)

The class deviation goes into effect on July 1, 2018. The text of the notice and the deviated provisions and clauses can be found here.

About William Van Huis

Bill Van Huis is a Senior Writer/Analyst for Wolters Kluwer Law & Business who tracks and analyzes new regulations impacting federal government contracting. He also follows court decisions involving bid protests and contract disputes. You can find his work in WK publications like Government Contract Reports and the FAR and DFARS Matrix Tools. Bill is a Certified Professional Contracts Manager, and he has a law degree from Southern Illinois University, where he graduated summa cum laude. Prior to joining WK, Bill worked both inside and outside state and local government in the areas of procurement and municipal finance. Bill also worked as a staff attorney for the Illinois Supreme Court.
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